|  FORD 
                    EXPLORER  ROLLOVER HISTORY OF STABILITY & 
                    DEFECTIVE TIRE  PROBLEMS   |  Chronology 
                    of Firestone / Ford    Recall 
                        & Knowledge Tire Defects   | 
                
                  |  | 1987 | 
                
                  | May 1, 1987 | A Ford internal memo states that 
                    the stability of the UN46 [Ford Explorer prototype] is worse 
                    than Bronco II and that it can be improved by widening, lowering 
                    and using a smaller P215 tire. | 
                
                  | June 11, 1987 | Ford internal memo on a meeting with 
                    Firestone reports that the ATX design is approved by Ford. | 
                
                  |  | 1988 | 
                
                  | Fall 1988 | Ford ADAMS reports states that the 
                    Explorer demonstrated "performance issues" at 35 psi 
                    but that they expected more favorable results at 26 psi. | 
                
                  | November 25, 1988 | An internal Ford Test Report shows 
                    Explorer lifts two wheels at 55 mph due to high center of gravity, 
                    tires and front suspension system. | 
                
                  |  | 1989 | 
                
                  | 1989 | Internal Ford document states that 
                    the cornering capacity of the Explorer is "[n]ot to exceed 
                    current [Bronco II] levels. Limit cornering capacity with larger 
                    tires through suspension revisions and tire pressure reduction." The document further discusses Tire Pressure Reduction:
                            "Engineering has recommended use of tire pressures below
                            maximum allowable inflation levels for all UN46 tires. As described
                            previously, the reduced tire pressures increase understeer and
                            reduce maximum cornering capacity (both 'stabilizing' influences).
                            This practice has been used routinely in heavy duty pick-up truck
                            and car station wagon applications to assure adequate understeer
                            under all loading conditions. Nissan (Pathfinder), Toyota,
                            Chevrolet, and Dodge also reduce tire pressures for selected
                            applications. While we cannot be sure of their reasons, similarities
                            in vehicle loading suggest that maintaining a minimal level of
                            understeer under rear-loaded conditions may be the compelling
                            factor." | 
                
                  | January 11, 1989 | An internal Ford memo reports a meeting 
                    with Firestone to discuss front suspension "jacking" 
                    on the Explorer and Bronco II, a phenomena that is "undesirable 
                    from a vehicle stability standpoint." | 
                
                  | January 26, 1989 | In an internal Ford memo, Ford engineers 
                    state the design goal [no two wheel lift] has not been met with 
                    the P235 ATX tire. | 
                
                  | February 9, 1989 | Ford hires Arvin Calspan to test 
                    the P245 tires. In a letter to James Avouris from George A. 
                    Tapia of the Arvin Calspan Tire Research Facility, Tapia reports 
                    that "[t]he P245 test tires at the 29 psi pressure condition 
                    showed a severe 'tread package' separation from the tire carcass." | 
                
                  | February 20, 1989 | In an internal Ford memo, Ford engineers 
                    recommend use of 26/26 (front/back) psi along with various other 
                    spring changes due to stability testing showing two wheel lift 
                    with 35 psi. | 
                
                  | March 2, 1989 | Internal Firestone memo to Ford states 
                    that "in light of Ford's decision to specify 26 psi in 
                    the P245 tire for the Explorer, Firestone has tested the vehicle 
                    at 26 psi front and 35 psi rear" . . . "Calspan testing 
                    showed severe tread separation, but our testing used a more 
                    realistic procedure and we don't think it will be a problem." | 
                
                  | April 5, 1989 | An internal Ford memo reports that 
                    Consumer's Union told Mr. Sloan, Ford Vice President of Public 
                    Relations: "You have a real problem" with your Bronco 
                    II. | 
                
                  | April 11, 1989 | Failure Analysis memo [Roger McCarthy] 
                    makes a proposal to Ford's lawyers to conduct Consumer's Union 
                    testing. | 
                
                  | April 21, 1989 | An internal Ford memo from Sloan 
                    to upper management (including Red Poling) following meeting 
                    with Consumer's Union reports that Ford staff has "clouded 
                    their minds." | 
                
                  | May 10, 1989 | Ford Test Report reveals that J-turn 
                    results still show that the Explorer "rolls over" 
                    in 5 of 12 tests. Blazer and Bronco II do not roll over. | 
                
                  | May 16, 1989 | Internal Ford memo emphasizes the 
                    importance of how the Explorer performs in the Consumer's Union 
                    (avoidance maneuver) test and the need to return to Arizona 
                    for more testing. | 
                
                  | May 17, 1989 | Memo from Ford Truck Operations Management 
                    authorizes Consumer's Union testing in Arizona. | 
                
                  | May 29, 1989 | Internal Ford memo tells management 
                    that there is a "risk" that the Explorer "won't 
                    pass" the Consumer's Union test. | 
                
                  | June 1989 | Consumer Reports article tells consumers 
                    they should "avoid" the Bronco II. | 
                
                  | June 15, 1989 | In an internal Ford memo to Truck 
                    Operations Managment, Ford engineer Jim Mason recommends design 
                    changes to the Explorer: * Lists eight possible changes
 * Analyzes them to show effect on stability index
 * Analyzes them with regard to "timing" of Job 1 [they
                    will delay Job 1].
 * Indicates Consumers' Union results show Explorer is same as
                    Bronco II
 * Says these design changes can make the Explorer as good as Blazer
 * Management recommends adopting as many as possible without
                      delaying Job 1.
 | 
                
                  | July 1989 | Ford memo indicating that Ford lowered 
                    the front of the Explorer half an inch and stiffened the front 
                    springs to increase stability. | 
                
                  | September 11, 1989 | In an internal Ford email to Charles 
                    White, Roger Stornant states, "I believe that new info 
                    is that our competitors are recognizing CU Test as a requirement 
                    and have designed their new utility vehicles to meet. OGC is 
                    concerned we will be the only OEM with a vehicle that has a 
                    significant chance of failing the CU test. I believe that management 
                    is aware of the potential risk w/P235 tires and has accepted 
                    risk. CU test is generally unrepresentative of real world and 
                    I see no 'real' risk in failing except what may result in wave 
                    of spurious litigation." | 
                
                  | September 12, 1989 | In an internal Ford email to Charles 
                    White, Roger F. Stornant expresses that OGC is concerned that 
                    the UN46 [Explorer] would fail Consumers Union tests with the 
                    P235 tires. "Based on the variability of the test, as demonstrated by
                      our own drivers, it is possible to pass the CU test with the P235
                      tires; however, if we were using the CU test as sign-off
                      requirement, we would not accept this combination (P235 ATX &
                      2dr)." | 
                
                  | December 1989 | Internal memo states that Explorer 
                    with 235 tires set at 26 psi passed the rollover test. | 
                
                  |  | 1990 | 
                
                  | February 1990 | In order to meet the production deadline, 
                    Ford officials rejected some proposals to improve the stability 
                    of the Explorer (i.e. widening the track width). | 
                
                  | March 1990 | JOB 1: '91-'94 Explorer [first date 
                    of manufacture]. | 
                
                  | May 1, 1990 | Ford asks Firestone in a letter from 
                    Jim Avouris to issue a dealer bulletin regarding tire replacement, 
                    emphasizing the importance of using the correct size tire and 
                    the correct air pressures on the Explorer [due to rollover sensitivity]. | 
                
                  | September 12, 1990 | In an email from Mazzola (Firestone) 
                    to Staples (Ford), Ford requests that Firestone (a) change the 
                    tire design to a low rolling resistance polymer and (b) change 
                    the tire pressure to 30/35 psi for a 1.6 mpg improvement on 
                    CAFE. The question is raised whether air pressure change will 
                    affect "vehicle dynamics," [i.e., rollover]. | 
                
                  |  | 1991 | 
                
                  | February 12, 1991 | FILED: Woodburn v. Firestone Tire 
                    and Rubber Co.; et al. [injuries unknown] | 
                
                  | February 14, 1991 | In a memo from Dave Wotton at Ford 
                    to Reichenbach at Firestone with tire objectives for the 1995 
                    model Explorer [UN105] shows that the goal is same traction, 
                    better rolling resistance and better wear properties. Timing 
                    is November 94. | 
                
                  | December 19, 1991 | Firestone memo from Reichenbach to 
                    Gibas at Ford saying it is "increasingly important" 
                    that we know whether you will adopt the tire for the Explorer. | 
                
                  |  | 1992 | 
                
                  | March 24, 1992 | FILED: Johnson v. Nissan, et al. 
                    [injuries unknown] | 
                
                  | April 23, 1992 | FILED: Cherinka v. Ford; et al [Explorer/ATX 
                    tread separation; injuries unknown] | 
                
                  | April 29, 1992 | FILED: Roberston v. Firestone/Bridgestone, 
                    Inc.; et al. [injuries unknown] | 
                
                  | May 10, 1992 | Letter from T.A. Mast & R. M. 
                    Campbell of Ford to Bridgestone/Firestone, Michelin, Goodyear, 
                    and General Tire to revise UPN105 Tire Targets. The primary 
                    objectives were to maintain tire wear, traction, and maximize 
                    rolling resistance. | 
                
                  | June 16, 1992 | Internal Ford memo entitled "Targets 
                    - UN105" contains: * "CANDIDATE TIRE - P235/75R15 
                    SL ALL TERRAIN OWL" * "NOTE: Primary importance should be placed on the 67"
                      drum rolling resistance."
 * "Tire pressure - 30 PSI for Ranger 4X4"
 * "Tire pressure - 26 PSI for Explorer"
 | 
                
                  | August 27, 1992 | Memo from J.E. Behr of Firestone 
                    to R.D. Bacigalupi, Ford Light Truck Engineering, answering 
                    questions from Ford about changing the design of the ATX to 
                    use a different tread compound for rolling resistance improvement. | 
                
                  |  | 1993 | 
                
                  | September 28, 1993 | A memo from Reichenbach at Firestone 
                    to Skyner at Ford asks to evaluate a tire wear concern on the 
                    10K testing as the '95 Explorer is exhibiting right front inside 
                    shoulder wear. | 
                
                  | December 22, 1993 | FILED: Blackaller v. Ford; Firestone; 
                    et al. [2 injuries, 2 deaths] | 
                
                  |  | 1994 | 
                
                  | April 12, 1994 | Ford Light Truck Operations Tire 
                    Construction Detail Sheet specifies the P235/75R15 tire at a 
                    maximum psi of 35. | 
                
                  | September 9, 1994 | FILED: Dreher v. Ford, et al. [injuries 
                    unknown] | 
                
                  | 1995 | Ford/Firestone begins shipping 16" 
                    Wilderness tire to Saudi Arabia. | 
                
                  |  | 1995 | 
                
                  | February 23, 1995 | FILED: Greenwald v. Bridgestone/Firestone, 
                    Inc.; Ford; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | August 7, 1995 | FILED: Ellis v. Bridgestone/Firestone, 
                    Inc.; Ford; et al. [Explorer/ATX; injuries unknown] | 
                
                  | August 7, 1995 | FILED: Dickson v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation from Wilson, NC plant; 
                    injuries unknown] | 
                
                  |  | 1996 | 
                
                  | January 4, 1996 | FILED: Combs v. Ford [Bronco II/ATX 
                    separation; 1 fatality] | 
                
                  | March 13, 1996 | Welch v. Ford; et al. [Explorer/ATX 
                    separation; 3 injuries] (incident date) | 
                
                  | June 20, 1996 | A memo from Arizona Game and Fish 
                    Department wildlife manager Lowell Whitaker to his regional 
                    supervisor describes two blow outs of Firestone tires. "During the past few months I have been cautioned as a user of
                    Firestone tires by DPS (Departement of Public Safety) that there
                    have been a series of accidents caused by the separation of the
                    tread from the tire on Firestone tires."
 | 
                
                  | July 1996 | FILED: Rogers v. Ford; et al. [Explorer/ATX 
                    separation; 1 injury, 1 fatality] | 
                
                  | July 12, 1996 | A memo from Deputy Yuma County (Arizona) 
                    Attorney John K. White regarding Firestone Firehawk ATX tires 
                    reported: "Some tires of this model have had their tread separate from
                    the body of the tire."
 "Firestone is aware of the problem and will be replacing tires
                    where needed. (A shipment of tires is currently on its way for
                    various Sheriff's vehicles.)"
 "It is strongly recommended that you do not drive vehicles
                    equipped with these tires at 'freeway speeds' (or at all, if
                    possible) until you have them...evaluated."
 | 
                
                  | July 22, 1996 | Letter from Robert J. Descheemaker 
                    at the Arizona State Procurement Office to Roger Abrams of Bridgestone/Firestone 
                    requesting replacement of all Firehawk ATX tires bought under 
                    state contracts. | 
                
                  | August 19, 1996 | Ford CQIS computer report on Explorer 
                    with 20k miles--Colonial Ford dealer in Danbury, Connecticut 
                    has 16 Explorers with distorted tires like this--belt is obviously 
                    distorted and about to separate | 
                
                  | August 26, 1996 | FILED: Gauvain v. Bridgestone Corporation; 
                    et al. [Explorer/ATX separation; 1 fatality] | 
                
                  | September 23, 1996 | FILED: Brizendine v. So. New. T.B.A. 
                    Supply Co., et al. [injuries unknown] | 
                
                  | December 27, 1996 | FILED: Guara v. Ford, et al [Bronco 
                    II/ATX separation; injuries unknown] | 
                
                  |  | 1997 | 
                
                  | January 17, 1997 | FILED: Kehm v. Bridgestone/Firestone, 
                    Inc.; et al. [Bronco/ATX separation; 3 injuries] | 
                
                  | February 21, 1997 | FILED: Spivak v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | June 1997 | Speed rating on tires in Venezuela 
                    changed from "R" [106 mph] to "S" [112 mph], 
                    with tires to be made in Venezuela. | 
                
                  | June 1997 | FILED: State Farm Mutual Automobile 
                    Insurance Company v. Bridgestone/Firestone, Inc. [injuries unknown] | 
                
                  | June 2, 1997 | FILED: Stephens v. Catherine A. Broome 
                    and Christopher D. Kehm; Bridgestone/Firestone; et al. [Bronco/ATX 
                    separation; 3 injuries] | 
                
                  | June 11, 1997 | Fax from Daryl G. Parma of Firestone 
                    to Luis Abreau states that tests show "how much better" 
                    the Wilderness AT (ST381J) is than the ATX II (SR897J) which 
                    would replace the ATX II. | 
                
                  | July 28, 1997 | FILED: Jackson v. Bridgestone/Firestone, 
                    Inc.; Ford; et al. [Explorer/ATX separation; 3 injuries, 1 fatality] | 
                
                  | August 1997 | An undated memo states Ford and Firestone 
                    are notified of tire problems in Saudi Arabia [from the Congressional 
                    notebooks] | 
                
                  | August 7, 1997 | FILED: Lazarus v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | September 16, 1997 | FILED: Silva v. Ford; et al. [Explorer/ATX 
                    separation; injuries unknown] | 
                
                  | September 22, 1997 | FILED: Carrillo v. Bridgestone/Firestone, 
                    Inc.; et al. [Blazer/ATX separation; 2 fatalities] | 
                
                  | October 21, 1997 | FILED: Chinichian v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | October 7, 1997 | FILED: Flores v. Ford; Bridgestone/Firestone, 
                    et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | December 1, 1997 | FILED: Ortiz v. Bridgestone/Firestone, 
                    Inc.; Ford; et al. [Explorer/ATX separation; 1 fatality] | 
                
                  |  | 1998 | 
                
                  | January 1998 | Glenn R. Drake, regional marketing 
                    manager in the United Arab Emirates for Ford expresses concern 
                    about Firestone's response to the tire problems in an email 
                    to other Ford executives: "If this was a single case, I would accept Firestone's response
                    as they are the experts in the tire business, case closed. However,
                    we now have three cases and it is possible that Firestone is not
                    telling us the whole story to protect them from a recall or a
                    lawsuit."
 | 
                
                  | January 9, 1998 | FILED: Haffey v. Ford; et al. [Explorer/ATX 
                    separation; 2 injuries, 1 fatality] | 
                
                  | January 22, 1998 | FILED: Huffman v. Ford; et al [Explorer/ATX 
                    separation; 2 injuries, 1 fatality] | 
                
                  | January 28, 1998 | FILED: Bragg v. Bridgestone/Firestone, 
                    Inc.; et al. [1 injury] | 
                
                  | April 23, 1998 | FILED: Van Etten v. Bridgestone/Firestone, 
                    Inc.; Ford [Explorer/ATX separation; 3 injuries, 1 fatality] | 
                
                  | April 24, 1998 | FILED: Parra v. Ford; et al. [Explorer/Wilderness 
                    HT; 2 injuries] | 
                
                  | May 15, 1998 | FILED: Kim v. Ford; et al. [Explorer/ATX 
                    separation; 2 injuries, 2 fatalities] | 
                
                  | June 24, 1998 | In an internal Bridgestone/Firestone 
                    interoffice memo to M. Hamaya Firestone, K. Ball acknowledges 
                    that P235/75R15 ATX II separation is 92.8% of all ATX II claims 
                    and 53.6% of all Firestone light truck claims for the year of 
                    1997. Additionally, warranty claims on ATX II tires jumped from 
                    42 in 1995 to 279 in 1997, a sixfold increase. 1998 light truck 
                    claims are 469 for separations and 8 for road hazards. 1997 light truck claims by plant for the ATX II show 117 for
                      Decatur, 101 for Wilson, and 51 for Joliette. | 
                
                  | July 13, 1998 | FILED: Simmons v. Ford; et al [Explorer/ATX 
                    separation; 2 injuries] | 
                
                  | July 22, 1998 | In an email to William Duckwitz at 
                    NHTSA from State Farm Associate Research Administrator Samuel 
                    Boyden, Boyden advises NHTSA of 21 Firestone ATX P235/75R15 
                    tire failures causing injuries. Fourteen cases were in 1991-1995 
                    Ford Explorers. The problem was dismissed as "unremarkable" 
                    by NHTSA. | 
                
                  | July 31, 1998 | FILED: Gutierrez v. Bridgestone/Firestone 
                    [Explorer/ATX separation; injuries unknown] | 
                
                  | August 27, 1998 | FILED: Lockwood v. Bridgestone/Firestone, 
                    Inc.; Ford; et al. [Explorer/ATX separation; 1 fatality] | 
                
                  | September 17, 1998 | FILED: Alvarez v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | October 24, 1998 | Ford Dealer Paul Wright, Technical 
                    Branch Manager, Al Jazirah Vehicles, expresses concern and frustrations 
                    in a letter to John W. Thompson, Tamimi Company Commercial Division 
                    that despite his warning about the safety of the tires, he did 
                    not receive a response and was being "kept in the dark 
                    to what is happening." | 
                
                  | October 24, 1998 (continued) | "As you know, this concern goes 
                    back to mid-1997 when we first notified you of this concern. 
                    I have to state that I believe this situation to be of a safety 
                    concern, which could endanger both the vehicle and more importantly 
                    the user of the vehicle. So I am asking what is going on? Do 
                    we have to have a fatality before any action is taken of this 
                    subject?" "I would recommend to ensure that we do not have any further
                            incidents regarding tyres that Firestone RECALL all 1995/1996/1997
                            explorers fitted with this type of tyre, as this is a safety related
                            concern." | 
                
                  | 1999 | Federal data from the Fatal Accident 
                    Reporting System for 1995-98 was available to Ford, Firestone, 
                    and NHTSA showing that Explorer fatalities were almost three 
                    times as likely to be tire related as those with other SUVs 
                    or cars and that Explorer crashes increased significantly in 
                    the late 1990s compared with other SUVs. | 
                
                  |  | 1999 | 
                
                  | January 1999 or after | Explorer Tire DNP - Exposed Findings 
                    of Tire Explosion and Car Rolling Due to Tire Inflation. Notes 
                    report of 22 Firestone and 10 Goodyear tread separations and 
                    rollover crashes. | 
                
                  | January 12, 1999 | FILED: Hill v. Bridgestone/Firestone, 
                    Inc. [5 injuries] | 
                
                  | January 19, 1999 | FILED: Wieters v. Bridgestone/Firestone, 
                    Inc.; et al. [ injuries unknown] | 
                
                  | January 22, 1999 | An email from D.J. Candido, to Firestone 
                    colleagues concluded that for countries prone to heat induced 
                    separation, the Wilderness HT, with European specs, was the 
                    best application choice. However, they also acknowledged that 
                    this model is more prone to chip and tear. The best choice is 
                    to develop a new tire with similar heat specs to the European 
                    model and similar chip/tear specs to the Australian model. | 
                
                  | January 27, 1999 | In an interoffice Bridgestone/Firestone 
                    memo entitled P255/79 R16 Wilderness AT Adjustment Data to Bruce 
                    Halverson, Market Quality Engineer, Nashville, Luis E. Abreu, 
                    Technical Service Manager, Firestone Venezuela, indicates that 
                    47 tires in Venezuela had tread or belt separation. Of these 
                    47, 34 had international serial codes and 13 had DOT (USA) code. In an attachment, Abreu further notes the most critical defects
                      from January 1995 to December 1998 are Tread leaving casing (135),
                      Belt leaving belt (136), Breaker leaving casing (137), shoulder
                      separation between rubber and casing (230), belt edge separation
                      (235). | 
                
                  | January 28, 1999 | In an email to Melanie Gumz, Glenn 
                    Drake of Ford reports that he is suspicious of Firestone's 
                    response to the problem and suggests that Firestone is not telling 
                    the entire story in order to protect themselves from lawsuits 
                    and a recall. Drake also questions the durability of the product 
                    and the fact that Ford is about to change the tire on all Explorers 
                    and mountaineers to a tire that has better high speed durability. 
                    Drake recommends that Ford conduct its own analysis in order 
                    to protect Ford and give the dealers and customers an independent 
                    opinion. "[W]e owe it to our customers and our shareholders 
                    to investigate this for our own peace of mind." | 
                
                  | January 1999 | In a memo to Firestone Distribution 
                    entitled Ford Explorer - Concerns in the Middle East (P255/70R16), 
                    John E. Behr, Account Executive for Original Equipment Tire 
                    Sales, reported, "I attempted to assure the Ford people 
                    that we are not aware of any defect with these tires, and that 
                    we've supplied over 1.1 million of the same tires to Ford over 
                    the past three years (1996 thru 1998) for usage in North America, 
                    with excellent field performances." | 
                
                  | January 29, 1999 | In a memo to Bridgestone/Firestone 
                    Distribution, John E. Behr, OE Sales, expresses that Ford is 
                    concerned that the tires in the Middle East are defective. Raises the issue of using the P255/70R16 Wilderness HT BSW H
                      instead of the P255/70R16 was requested by Ford. He advised that the
                      H tire would be better suited for high speed driving and more
                      resistant to heat buildup but would not be more puncture resistant. | 
                
                  | February 8, 1999 | FILED: Menendez v. Ford, Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | February 14, 1999 | In a letter to Keshav Das, Technical 
                    Service Department of Firestone at Dubai, John Garthwaite, Ford 
                    National Service Director, Al Jazirah Vehicles (Ford Dealer 
                    in the Middle East), warns Bridgestone/Firestone of the serious 
                    nature of the problem with P255/70/R16 AT tires. Garthwaite 
                    indicates that an accident occurred with a tire at 30 psi. The 
                    tread separated completely and the tire remained inflated. Garthwiate 
                    expressed his strong conviction that there is a "distinct 
                    problem with all or at least a certain production run of this 
                    particular tyre." | 
                
                  | February 25, 1999 | Garthwaite continues to question 
                    the safety of the P255/70/R16 tire in a subsequent letter to 
                    Keshav Das. "These incidents involving Firestone P255/70/R16 
                    tyres is beginning to become an epidemic." He further states 
                    that "Nothing in your reply has done anything to re-assure 
                    me that there may not exist a defect in a particular batch of 
                    your product . . ." | 
                
                  | March 11, 1999 | An internal Bridgestone/Firestone 
                    Letter to S. Katsura, et. al. from Firestone Account Executive, 
                    John E. Behr expresses concern over the result of Ford's proposed 
                    consumer notification program and the potential effects and 
                    "perception" it would convey in Saudi Arabia as well 
                    as "complications it could create in North America." 
                    The letter also indicates that other Ford people also disfavored 
                    the notification program. Ford planned to change the tire in the Middle East to the H-rated
                      European tire that is more heat resistant. | 
                
                  | March 12, 1999 | An internal Ford memo to Dave MacKinnon 
                    from Church Seilnacht states the following: "John [Behr] also reaffirmed that the "H" rated
                      tire is the most resistant to damage from underinflated
                      operation." | 
                
                  | March 12, 1999 (continued) | "Firestone legal has some major 
                    reservations about the plan to notify customers and offer them 
                    an option. First, they feel that the U.S. D.O.T. will have to 
                    be notified of the program, since the same product is sold in 
                    the U.S. Second, they are afraid that the Saudi government will 
                    see this as a recall and react dramatically, including prohibiting 
                    the import of the current OEM tire. They believe the best course 
                    of action for the vehicles already in the market is to handle 
                    the tire issues on a case-by-case basis." "Related to the Firestone legal concerns is the possibility
                            that we will be expanding the owner relations issue. The owners who
                            receive the notification letter may see the program as a recall and
                            not be willing to pay anything to upgrade the tires. So, instead of
                            8 owner relations issues, we now have X times as many." "I [talked to] Corey MacGillivray in the OGC last Monday
                      about the proposal. He didn't think that working on a case-by-case
                      basis with the owners of the damaged vehicles presented a problem,
                      but he was concerned about the implications of the owner letter
                      (similar to the Firestone concerns)." | 
                
                  | April 27, 1999 | FILED: Glick v. Firestone Tire and 
                    Service Center, et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | April 28, 1999 | Ford memo on Firestone Tire Tread 
                    Separations states that Ford will "address the issues related 
                    to the rollovers on a case-by-case basis." | 
                
                  | May 4, 1999 | FILED: Healy v. Bridgestone/Firestone, 
                    Inc. [Explorer/ATX separation; 1 injury] | 
                
                  | May 4, 1999 | FILED: Patterson (Elroy) v. Bridgestone/Firestone 
                    [injuries unknown] | 
                
                  | May 4, 1999 | In a fax from Arabian Car Marketing 
                    to Ford Middle East and North Africa Company, Oman Ford advises 
                    Ford Middle East that it is replacing Firestone tires with Michelin 
                    tires prior to delivery because Explorer users are becoming 
                    aware of (through the internet) the off-road limitations of 
                    the Explorer. | 
                
                  | June 24, 1999 | FILED: Jenkins v. Bridgestone/Firestone, 
                    Inc. [injuries unknown] | 
                
                  | June 30, 1999 | Fax labeled "Top Urgent & 
                    Very Important" to Ford Middle East from Arabian Car Marketing 
                    Company warns Ford Middle East and North Africa that the tires 
                    are failing: "news of fatal accidents on Explorer is spreading 
                    rapidly." "The tire problem has already resulted in 
                    a severe decline in Explorer sales." "We are also 
                    worried about further fatalities and possible lawsuits." | 
                
                  | July 2, 1999 | FILED: Jenkins v. Bridgestone/Firestone, 
                    Inc.[injuries unknown] | 
                
                  | July 7, 1999 | FILED: Meza v. McCombs HFC Limited 
                    D/B/A Red, et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | July 16, 1999 | FILED: Progressive County Mutual 
                    Insurance Company v. Bridgestone/Firestone, Inc. [Explorer/ATX 
                    separation; injuries unknown] | 
                
                  | July 28, 1999 | FILED: Jarvis v. Bridgestone/Firestone, 
                    Inc. [Explorer/ATX separation; injuries unknown] | 
                
                  | July 30, 1999 | FILED: Taylor v. Bridgestone/Firestone, 
                    Inc. [Explorer/ATX separation; injuries unknown] | 
                
                  | August 2-5, 1999 | Teams from Ford and Bridgestone/Firestone 
                    recognize Ford Explorer rollover due to tread leaving casing 
                    in the Venezuelan Tire Survey of problem tires. Suggested 
                    possible causes are excessive speed (173 Km/hr (26 Km in 9 minutes)), 
                    heavy load (8 passengers plus luggage), and high pavement temperature 
                    (55 degrees Celsius at 1:20 pm). Suggested possible results 
                    were tire fatigue and separations. 132 tires inspected at dealers 
                    in 4 locations revealed 8 underinflated tires (Wilderness P255/70R/16AT 
                    and P235/75R/15ATX) The teams suggested as one of the possible actions to improve the
                      circumstances in Venezuela, increasing the recommended
                      inflation pressure on the vehicle from 28 to 30 in the front and
                      from 26 to 30 in the back. The 30 psi standard was considered to be
                      the USA standard of inflation. | 
                
                  | August 6, 1999 | FILED: Aoyagi v. Bridgestone/Firestone, 
                    Inc.; et al. [injuries unknown] | 
                
                  | August 9, 1999 | Letter from B.V. Halverson to Mr. 
                    J. Gonzalez of Bridgestone Firestone acknowledges that "sustained 
                    high speed driving must be considered as a normal input in the 
                    performance of vehicles and tires in Venezuela." Mr. Carlos 
                    Maren "really wanted a BFS recommendation that would guarantee 
                    that a tire would never have a separation." | 
                
                  | August 12, 1999 | FILED: Romero v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | August 13, 1999 | FILED: Jimenez v. Bridgestone/Firestone, 
                    Inc. [Explorer/ATX separation; injuries unknown] | 
                
                  | August 17, 1999 | Ford begins replacing tires on Saudi 
                    Explorers through a "customer notification enhancement 
                    action" and not a "recall." Excerpts from correspondences regarding the "Owner
                            Notification Program" "Unique GCC usage patterns, environmental conditions and
                      maintenance practices may result in tire degradation and
                      potentially, tread separation. Nineteen rollovers, fourteen
                      fatalities and ten injuries are alleged to have been attributed to
                      this condition." | 
                
                  | August 17, 1999 | Approximately 6,800 1995-99 MY Explorer 
                    and Mountaineer vehicles produced at the Louisville Assembly 
                    Plant from Job 1, 1995, through July 30, 1999, are potentially 
                    affected." "Based on the Field Review Committee recommendation, a field
                            action has been approved to request owners to return potentially
                            affected vehicles to dealers for replacement of the Firestone
                            Wilderness brand tires with Goodyear Wrangler brand tires." | 
                
                  | August 19, 1999 | FILED: De Leon v. Bridgestone/Firestone, 
                    Inc.; et al. [injuries unknown] | 
                
                  | August 23, 1999 | In a letter to owners of light truck 
                    vehicles, Bridgestone/Firestone offers free tire inspection 
                    and free rotation service as a special offer to Venezuelan owners 
                    of light truck vehicles. | 
                
                  | August 27, 1999 | In a letter to C.E. Mazzorin, Ford's 
                    L.A. Klein indicates that the tire problems in the Middle East 
                    are largely due to the fact that the tire was not designed for 
                    the Middle Eastern market. The tire's speed rating is "S" 
                    which allows for speeds up to 112 mph. The Middle East requires 
                    higher speed ratings. | 
                
                  | September 1999 | In a letter to it's GCC dealers, 
                    Ford stated: "Ford and Firestone have been working to identify a Firestone
                    tire that we can recommend that may offer a greater margin of
                    resistance to puncture and or tread separation for the conditions
                    unique to the GCC region than the current tire. That tire has been
                    identified as the 'special service' tire currently available only in
                    the Saudi Arabian market. This tire is more puncture resistant than
                    the current production tire.
 | 
                
                  | Fall 1999 | Ford began replacing Firestone tires 
                    on Explorers in ten Middle East countries. | 
                
                  | September 1, 1999 | FILED: Hendricks v. Bridgestone/Firestone, 
                    Inc. [Explorer/ATX separation; injuries unknown] | 
                
                  | September 3, 1999 | FILED: Bean v. Bridgestone/Firestone, 
                    Inc.; et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | September 9, 1999 | FILED: Porsche v. Ford, Bridgestone/Firestone, 
                    Inc. [3 injuries] | 
                
                  | September 12, 1999 | In a letter from John Garthwaite, 
                    National Service Director, Al Jazirah Vehicles, Saudi Arabia, 
                    to David MacKinnon, Director of Ford Customer Service, Dubai, 
                    Garthwaite once again advises of tread separation problems in 
                    Saudi Arabia. He suggests an in-depth Firestone tire investigation. 
                    "I am afraid that I can see a pattern emerging here. The 
                    tyre in this second case is totally destroyed but it is clear 
                    to me that the body damage is indicative of tread separation 
                    in the first instance." | 
                
                  | September 13, 1999 | FILED: Smith v. Bridgestone/Firestone, 
                    Inc.; et al. [injuries unknown] | 
                
                  | September 14, 1999 | Ford memo entitled "1995/99 
                    Explorer/Mountaineer Firestone P255/70R16 Tire Separation in 
                    the United States" states: "While driving vehicle, the tire tread separated from the
                      main carcass of the tire. The tire failure is discovered when the
                      driver hears the tire tread hitting the wheel house or the tire goes
                      flat." "MORS (Master Owners Relation System) - Reviewed all 95/99
                      MORS reports (4236) for tires and wheels. Found 32 'possible' tread
                      separation claims on Firestone (22) and Goodyear (10). 3 of the 32
                      possible claims were for the P225/70R15 tire from Firestone. 10 of
                      the 32 possible claims were for the P235/75R15 tire from Goodyear.
                      18 of the 32 possible claims were for the P235/75R15 tire from
                      Firestone." | 
                
                  | September 15, 1999 | Internal Ford memo from Carlos Mazzorin 
                    to Jac Nasser and others: The attachment dated August 27, 1999 states: "Issue description: While driving the vehicle at high
                      speeds, for prolonged periods of time, the tire tread separated
                      (belt edge separation) from the main carcass of the tire. 19
                      rollovers attributed to this issue have occurred in Saudi Arabia,
                      Oman and Qatar combined. Several fatalities have resulted. The issue
                      has also occurred in Venezuela, and fatalities have also resulted in
                      that market. No known instances have occurred in other
                      markets." "Ford first became aware of the issue in GCC markets in
                      December 1998." In Venezuela, Ford "discovered the issue
                      in early Spring 1999." | 
                
                  | September 17, 1999 | FILED: Douglas v. Ford; Bridgestone/Firestone; 
                    et al. [Explorer/ATX separation; injuries unknown] | 
                
                  | October 1, 1999 | Interoffice memo from L.A. Klein 
                    to C.E. Mazzorin reveals Ford's admission that it was responsible 
                    for choosing to use the North American tire in the GCC (Gulf 
                    Countries) market and determines the tire was not suitable for 
                    this area. Firestone was not part of that decision. | 
                
                  | October 1, 1999 (continued) | GCC Market: * "Negotiations with Firestone have stopped. Firestone's
                        position that the tire meets all quoted functional specifications,
                        and that it was not meant for the GCC market application is
                        confirmed by our research. It appears that Ford chose to use the
                        North American specified tire in the GCC market, and Firestone was
                        not part of that decision." Ford also indicates that the tires failing in Venezuela were
                      specifically designed for the Venezuelan market and therefore the
                      responsibility lies with Firestone. | 
                
                  | October 19, 1999 | Report entitled 1999 Firestone Quarterly 
                    Meeting: Critical Performance Issues, Aiken, SC indicates that 
                    tire separations were up to 3365 from 2929. Belt edge separation 
                    up 18.3%, belt leaving belt was up 10.1%, and SW separation 
                    - rubber from casing was up 63.6% for 1999 third quarter compared 
                    to 1998. This report does not separate out the individual tires. Firestone Adjustment Performance - Service Group states that more
                      improvement in separations are needed to reduce LT REC adjustments. Firestone Adjustment Performance of major lines indicated that
                      Wilderness AT and Wilderness HT experienced increases in adjustments
                      related to Ford F150 sizes. The adjustment analysis also indicates that Firestone Light Truck
                      - recreational experienced an increase in belt edge separation (up
                      22.3%), belt leave belt (up 11.1%), and SW SEP - Rubber from casing
                      (up 69.6%). | 
                
                  | October 19, 1999 | The Radial ATXII also experienced 
                    a 5.2% increase in belt edge separation. Firestone report indicates that Decatur plant experiences
                      substantial number of problems compared to the other plants. | 
                
                  | November 10, 1999 | FILED: Guillen v. Bridgestone/Firestone, 
                    Inc., et al. [injuries unknown] | 
                
                  | December 21, 1999 | FILED: Gilmore v. Bridgestone/Firestone; 
                    et al. [injuries unknown] | 
                
                  |  | 2000 | 
                
                  | 2000 | In the 1999 vs. 1998 Adjustments 
                    data, Firestone revealed that Wilderness tire separations increased 
                    194% and Wilderness adjustments were "growing quickly." | 
                
                  | 2000 est. | In a Firestone document "Explorer 
                    Tire DNP" giving status report: "In July 1997 [Ford Venezuela] representatives were called
                      to a meeting in Caracas with a group of independent lawyers
                      representing four (4) customers. The objective of this meeting as
                      expressed by these lawyers, was to draw Ford attention to a
                      situation related to their customers, but that they felt could be
                      greater." "High incidence of vehicle rollover after a tire blowout or
                      tread loss has not been detected for other vehicle brands: Toyota,
                      GM, and Chrysler all have significant market presence in this market
                      segment." | 
                
                  | January 1, 2000 | In a Bridgestone/Firestone 1999 Year 
                    End Minor Profit Loss Report from William Thomas to Dave Laubie, 
                    attached charts show 1998 and 1999 data on tire tread separations 
                    by tire type and plant indicating large numbers of tread separations 
                    in tires manufactured at Decatur plant and with 235/75R15 tire. 
                    The report also shows increasing claims for SXR4S Tire in 1999. 
                    Overall separation are up 10 in 1999 over 1998. 25% of total 
                    separations in 1999 were ATX II. | 
                
                  | February 2000 | Ford offers free replacement tires 
                    for vehicles in Malaysia and Thailand. | 
                
                  | February 2000 | Officials from Bridgestone/Firestone 
                    were briefed as early as February about rising warranty costs 
                    for the now recalled tires according to internal Bridgestone/Firestone 
                    documents including a series of charts distributed at a sales 
                    meeting in February, 2000. One chart tracking "separations 
                    increasing" revealed that the number of warranty claims 
                    for tread separation had risen from 4,200 in 1998 to 4,694 in 
                    1999 (an increase of 11.8 percent). Another chart stated that 
                    "Wilderness AT needs improvement." While still other 
                    charts analyzed patterns in tread separations emphasizing tires 
                    for light trucks. These charts revealed that the number of tread 
                    separations involving Wilderness tires had risen 144 percent 
                    from 1998 to 1999. | 
                
                  | February 7, 2000 & Feb. 10, 
                    2000 | KHOU, CBS affiliate station in Houston, 
                    breaks story of significant numbers of deaths and lawsuits with 
                    Firestone tires on Ford Explorers. Firestone Statement on February 
                    4 before the programs aired says: "The Radial ATX has proved 
                    to be a reliable workhorse for U.S. consumers. Our experience 
                    with the Radial ATX indicates high consumer satisfaction with 
                    the quality and reliability of these tires. No court or jury 
                    has ever found any deficiency in these tires." | 
                
                  | February 10, 2000 | In a letter from Christine Karbowiak, 
                    Vice President, Public Affairs, Firestone, to Robert Decherd, 
                    Chairman, President and CEO of A.H. Belo Corp., and Peter Diaz, 
                    President and General Manager of KHOU-TV, Firestone states that 
                    KHOU-TV's broadcast series regarding its tires, "contains 
                    falsehoods and misrepresentations that improperly disparage 
                    Firestone and its product, the Radial ATX tire." It further 
                    asserts, "This series has unmistakably delivered the false 
                    messages that Radial ATX tires are dangerous, that they threaten 
                    the safety of anyone using them, and that they should be removed 
                    from every vehicle on which they are installed. Each of these 
                    messages is simply untrue." | 
                
                  | February 25, 2000 | Bridgestone/Firestone report indicates 
                    that separations in Wilderness tires are on the rise, but ATX 
                    are decreasing. | 
                
                  | March 5, 2000 | NHTSA ODI resume (IE00-016 ' different 
                    from current investigation file number) indicates 22 complaints, 
                    8 crashes, and 4 fatalities due to tire tread separation. (All 
                    ODI complaints are sent to company when received.) | 
                
                  | March 6, 2000 | NHTSA opens preliminary inquiry after 
                    KHOU-TV programs prompted consumer complaints. | 
                
                  | March 22, 2000 | Firestone survey of 243 tires on 
                    63 vehicles that were trade-ins or lease return vehicles shows 
                    that 31% of the 15" tires were under-inflated and 51% of 
                    the 16" tires were under-inflated and at total of 9 tires 
                    had less than 20 psi. | 
                
                  | April 25, 2000 | In response to a request from NHTSA, 
                    Samuel Boyden, State Farm Associate Research Administrator, 
                    emailed a breakdown by calendar year and tire type (Firestone 
                    ATX, ATX II, and Wilderness tires) for the period covering 1996 
                    to April 2000. This contained information on 70 reports. | 
                
                  | May 2000 | Ford offers to replace tires for 
                    customers in Colombia, Ecuador and Venezuela. | 
                
                  | May 2000 | Ford shifts to Goodyear tires in 
                    Venezuela as it waits for a U.S. Firestone response. Ford's 
                    action covers about 39,800 vehicles. | 
                
                  | May 2, 2000 | NHTSA opens investigation of 47 million 
                    ATX, ATX II, and Wilderness Firestone tires (investigation number 
                    PE00-020) with 90 complaints reporting 33 crashes including 
                    4 fatal crashes and 17 injury crashes resulting in 27 injuries 
                    and 4 fatalities. Unknown to NHTSA, lawsuits and notices of intent to file involved
                      at least 35 fatalities and 130 injuries. | 
                
                  | May 8, 2000 | NHTSA sends a list of interrogatories 
                    to Bridgestone/Firestone as part of its investigation of the 
                    tire failures. NHTSA requests that Firestone respond by June 
                    19th. | 
                
                  | May 10, 2000 | NHTSA sends a list of interrogatories 
                    to Ford as part of its investigation of the tire failures. NHTSA 
                    requests that Ford respond by June 23rd. | 
                
                  | June 6, 2000 | Internal Ford Memo lists 21 vehicles 
                    sold in Gulf Countries. Lists Explorer (in Venezuela) psi at 
                    28/28 for the 15" tire. The new 15" tires are listed 
                    at 30/30. | 
                
                  | June 16, 2000 | Ford requests an extension of the 
                    deadline to respond to NHTSA's interrogatories with an anticipated 
                    completion date of October 13th. | 
                
                  | June 20, 2000 | In response to NHTSA's interrogatories, 
                    Bridgestone/Firestone submits a partial response. | 
                
                  | June 22, 2000 | NHTSA grants Bridgestone/Firestone 
                    an extension until August 14th to provide information in response 
                    to its interrogatories. | 
                
                  | July 24, 2000 | In response to NHTSA's interrogatories, 
                    Ford submits a partial response. | 
                
                  | July 25, 2000 | After a story aired on KCBS regarding 
                    Ford Explorers and ATX tires, Firestone instructed dealers to 
                    replace tires with Bridgestone or Firestone tires of the customer's 
                    choice. However, "[t]his sale should be a regular sales 
                    ticket. Do not use an adjustment ticket." [Adjustments 
                    (warranties) are used by NHTSA and industry to track defects.] | 
                
                  | July 31, 2000 | Public learns of Ford's replacement 
                    of Firestone tires on Explorers in Venezuela. | 
                
                  | July 31, 2000 | Ford submits another partial response 
                    to NHTSA's original interrogatories. | 
                
                  | August 2, 2000 | NHTSA reports it is probing 21 deaths 
                    in crashes of pickup trucks and SUVs where tire failure may 
                    have played a role | 
                
                  | August 4, 2000 | Sears, Roebuck & Co., the No. 
                    1 tire retailer, stops selling certain Firestone tires. | 
                
                  | August 4, 2000 | Ford submits another partial response 
                    to NHTSA's original interrogatories. | 
                
                  | August 6, 2000 | Firestone announces a "customer 
                    information notice" in Venezuela in which certain models 
                    of tires would be replaced. | 
                
                  | August 7, 2000 | NHTSA announces investigation of 
                    46 deaths related to the Firestone tires. Discount tire and Montgomery Ward suspend sales of Firestone
                      tires until more information is made available. | 
                
                  | August 9, 2000 | Firestone/Bridgestone voluntarily 
                    recalls 6.5 million 15" ATX, ATX II, and Wilderness AT 
                    from the Decatur plant. (14.4 manufactured) | 
                
                  | August 14, 2000 | Bridgestone/Firestone asks NHTSA 
                    to again extend its deadline to respond to NHTSA's initial interrogatories 
                    until September 5th. | 
                
                  | August 15, 2000 | NHTSA raises the number of traffic 
                    deaths linked to Firestone tires from 46 to 62. It is also looking 
                    into reports of 100 injuries. | 
                
                  | August 18, 2000 | Ford's partial response to NHTSA's 
                    inquiries. | 
                
                  | August 28, 2000 | Bridgestone announces a boost in 
                    replacement production to 650,000. | 
                
                  | August 29, 2000 | NHTSA requests supplemental information 
                    from Ford as part of its ongoing investigation of the Firestone 
                    tire failures. NHTSA requests that Ford respond by September 
                    31st. | 
                
                  | August 31, 2000 | Venezuela's consumer protection agency, 
                    Indecu, asked prosecutors to bring criminal charges against 
                    both Bridgestone/Firestone and Ford. Ford's Jacques Nasser responded 
                    by stating, "The accusation from the Venezuelan government 
                    that Ford Venezuela lied is absolutely unfounded." Venezuelan 
                    authorities contend that Ford and Firestone held secret meetings 
                    to determine what was wrong following the first reports of incidents 
                    in 1998. Instead of instituting a recall, officials allege that 
                    Ford asked Firestone to redesign the Wilderness tire. | 
                
                  | August 31, 2000 | NHTSA raises to 88 from 62 the number 
                    of deaths associated with the Firestone tires. Venezuelan consumer agency, Indecu, recommends that Ford and
                      Firestone be prosecuted for 46 deaths related to the tires in
                      Venezuela. | 
                
                  | September 1, 2000 | Firestone declines NHTSA's request 
                    to voluntarily expand recall to 1.4 million tires not included 
                    in the original recall. NHTSA issues consumer advisory on additional 1.4 million
                      Firestone tires. NHTSA states that some of the tires have "high
                      tread separation rates." | 
                
                  | September 4, 2000 | Bridgestone/Firestone issues a recall 
                    in Venezuela of 62,000 Venezuelan-made 15-inch and 16-inch Wilderness 
                    tires. Previously, only US-manufactured tires were being replaced. | 
                
                  | September 4, 2000 | Bridgestone/Firestone reaches agreement 
                    with union to settle labor disputes and avert a strike at nine 
                    U.S. plants. | 
                
                  | September 6, 2000 | Mr. Wyant, Firestone Vice President 
                    of Quality Assurance, testified that, "They [Ford] see 
                    every bit of the field performance data that is devoted to approving 
                    a tire." | 
                
                  | September 6, 2000 | The Senate Appropriations Committee 
                    and House Commerce Sub Committees conduct separate hearings 
                    on the Bridgestone/Firestone-Ford tire recall. | 
                
                  | September 8, 2000 | Ford states in a filing with the 
                    Securities and Exchange Commission that "we have preliminarily 
                    agree to bear a portion of the costs of Firestone's recall." | 
                
                  | September 12, 2000 | Public Citizen President Joan Claybrook 
                    delivers testimony before the United States Senate Committee 
                    on Commerce, Science and Transporation on Ford and Firestone's 
                    knowledge of the safety defects, NHTSA's legislative and enforcement 
                    weaknesses and calls for an expanded recall. | 
                
                  | September 18, 2000 | Public Citizen files amicus curaie 
                    brief in support of plaintiff's motion to compel and opposition 
                    to protective order in the case of Trahan v. Ford Motor 
                      Co. and Bridgestone/Firestone. | 
                
                  | September 20, 2000 | Sen. Richard Shelby (R-Ala.) drops 
                    a provision that would have prevented NHTSA from issuing a consumer 
                    information test on motor vehicle rollover. | 
                
                  | September 20, 2000 | Sens. McCain and Hollings and the 
                    Senate Commerce Committee propose new auto safety legislation 
                    that would strengthen NHTSA's incentive and enforcement powers 
                    but would "not require companies to test their products 
                    before certifying that they comply with federal motor vehicle 
                    safety standards." | 
                
                  | September 26, 2000 | Senate Commerce Committee auto safety legislation 
                    (S. 3059) as reported promises to strengthen safety regulations 
                    but fails to "establish criminal penalties for knowingly 
                    selling vehicles that do not comply with safety standards, for 
                    failing to notify the Secretary of Transportation and the public 
                    of safety defects or noncompliance with safety standards, and 
                    for refusing to comply with the recall provisions of the Safety 
                    Act," Public Citizen's analysis of the legislation said. | 
                
                  | September 27, 2000 | Auto safety legislation reported 
                    by the Telecommunications, Trade and Consumer Protection Subcommittee 
                    of the House Commerce Committee "drastically 
                    limits the information that manufacturers will have a duty to 
                    provide to NHTSA on a regular basis, and sets up numerous hurdles 
                    which the agency must jump over before being able to accomplish 
                    basic rulemaking on the content of manufacturer's submissions." | 
                
                  | October 2, 2000 | Firestone agrees to release by October 
                    9, 2000 all test results, quality assurance and adjustment data, 
                    and all correspondence between Ford and Firestone concerning 
                    specifications and criteria from Ford and the manufacture, design, 
                    testing and failure of the ATX tire -- documents that the company 
                    had previously attempted to keep secret. | 
                
                  | October 11, 2000 | The U.S. Senate unanimously passes 
                    H.R. 5164, the Transportation Recall Enhancement, Accountability 
                    and Documentation Act (T.R.E.A.D.), which becomes public law 
                    on November 1, 2000 | 
                
                  | October 31, 2000 | Public Citizen releases report showing 
                    that the auto industry has contributed $37.8 million to lawmakers 
                    since 1995, 75 percent of which went to Republicans. | 
                
                  | November 21, 2000 | Goodyear reveals that safety defects 
                    in its Load Range E tires have led to at least 15 deaths and 
                    129 injuries. The company had been aware of the defects but 
                    faces no criminal penalties. | 
                
                  | December 2, 2000 | Ford's former vice president for 
                    quality assurance, robert O. Martin, testifies that tires produced 
                    at the Decatur plant may have been overrespresented in fatal 
                    crashes because they were installed in warm-weather states. | 
                
                  | December 11, 2000 | Ford officials tell NHTSA that flaws 
                    in designs and manufacturing processes of Firestone tires are 
                    to blame for tire failures, not the vehicles themselves. "Our 
                    experience...leads us to conclude that the vehicle is not a 
                    significant contributor to tread separation," according 
                    to their report. | 
                
                  | December 17, 2000 | NHTSA reports that 148 deaths and 
                    525 injuries can now be attributed to crashes involving Ford 
                    Explorers and Firestone tires. | 
                
                  | December 21, 2000 | Tom Baughman, engineering director 
                    for Ford's truck operations, states in a deposition that the 
                    15-inch Wilderness AT tires "are not robust against variations 
                    and inflation pressure and in operating condition, load and 
                    speed." | 
                
                  |  | 2001 | 
                
                  | January 4, 2001 | Evidence compiled by Public Citizen 
                    and Safetyforum.com reveals that Ford and Firestone limited 
                    last year's recall to tires made at the Decatur, Ill. plant, 
                    analyzed only one narrow database and ignored information about 
                    tire failures that spawned major litigation claims, consumer 
                    complaints and adjustment records that show replacement of equipment 
                    under warranty. | 
                
                  | January 9, 2001 | NHTSA releases a new rollover rating 
                    program, but the star rating system is limited because it is 
                    static and purely informational. | 
                
                  | February 2, 2001 | Firestone releases report on the 
                    causes of tread separation showing that the rate at which customers 
                    brought their tires in for problems was essentially the same, 
                    whether the tires were made at plants in Decatur, Ill., Joliet, Quebec or 
                    Wilson, N.C. | 
                
                  | April 25, 2001 | Public Citizen and Safetyforum.com 
                    release report concluding that approximately 10 million non-recalled 
                    15-inch Wilderness tires and 16-inch Wilderness AT tires should 
                    also be recalled, as they are subject to the same design flaws 
                    as the 6.5 million recalled tires. | 
                
                  | June 19, 2001 | Joan Claybrook's submitted testimony 
                    to two House subcommittees investigating the issue encourages 
                    NHTSA to raise its standards for rollover crashworthiness. | 
                
                  | June 27, 2001 | Safety consultant Sean Kane asserts 
                    in a New York Times article that some consumer lawyers 
                    may have been aware of patterns of failure in Firestone tires 
                    but did not alert NHTSA, due to private lawsuits. | 
                
                  | August 24, 2001 | Bridgestone/Firestone Inc. agrees 
                    to pay $7.5 million to settle a case brought by Dr. Joel Rodriguez 
                    and his wife, Marisa, who was injured in a rollover crash. This 
                    was the first crash involving a Ford Explorer and Wilderness 
                    AT tire that had gone to trial. | 
                
                  | August 27, 2001 | The Wall Street Journal reports that 
                    the federal government has linked 203 deaths and over 700 injuries to 
                    the Ford Explorer and Firestone tires. | 
                
                  | October 4, 2001 | Firestone announces that it will 
                    recall 3.5 million additional Wilderness AT tires manufactured 
                    prior to 1998 at plants other than the Decatur, Ill. plant. | 
                
                  | YEAR  2002 | Blame starts to shift from Firestone to Ford for
                    the high rollover rate of the Ford Explorer. |